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Conducting SEPA for Nonproject Actions

Results of Feasibility Testing

December 2001

Summary of Findings

The following are some of the likely consequences if the process and NPRF are adopted as amendments to Chapter 197-11 WAC:

  • Improved environmental analysis for nonproject actions with moderate impacts
  • Reduction of time spent on environmental analysis after proposal is developed
  • Improvements in public/agency opportunity to provide meaningful input
  • Greater integration of planning and environmental analysis
  • Additional resource expenditure commensurate with improvements in environmental analysis
  • Adjustment period needed for agencies/public


The Department of Ecology (Ecology) is initiating changes to the environmental review process of nonproject actions under the State Environmental Policy Act (SEPA), Chapter 43.21C RCW. The amendments will include a new tool to guide and document the requirements for all nonproject actions. The new Nonproject Review Form (NPRF) will replace the existing checklist and Supplemental Sheet for Nonproject actions, WAC 197-11-960, as they apply to nonproject actions.

Also, the SEPA Rules (Chapter 197-11 WAC) will be amended to include changes in the process for conducting environmental analysis using the NPRF. As part of this effort, the new form and process were tested under the provisions of the Administrative Procedures Act. This report summarizes the effort and the results from the testing.


SEPA requires each state and local government agency to consider the likely environmental consequences of a proposal before taking an action (making a decision). This is particularly important for nonproject actions that will govern the development of multiple future projects and for regulations that contain standards controlling use or modification of the environment.

Thus, a systematic approach for integrating environmental review with planning could further identify aspects for evaluation and encourage better quality plans, policies and regulations. In turn, the more detailed the review at the planning phase, the more streamlined the review at the project stage.


The current environmental checklist and the process used to conduct nonproject environmental analysis are widely recognized as being severely deficient in both promoting environmental values to be considered in decision making, as well as the types of information required. Among the problems are:

Many lead agencies conducting environmental analysis under SEPA do not begin the analysis until a draft plan or policy is prepared. By this time, interested parties have bought into the draft, compromises have been made, and unless the environmental impacts are egregious, significant changes are difficult or impossible. Thus SEPA becomes an "add-on" that results in added costs and delay with few environmental improvements.

The existing tool used to make threshold determinations for most nonproject proposals is the project environmental checklist plus a supplemental sheet for nonproject actions. There appears to be a universal opinion that the existing checklist does not work well for nonproject proposals. A common comment from planners and others when asked about how they use the checklist is; "We simply write N.A. (not applicable) for most or all of the questions about impacts to the environment."

There is an opportunity to remedy these problems by implementing better processes, procedures, and guidance that will meaningfully incorporate the consideration of environmental values, impacts and alternative analysis into the decision making process.


In developing the Nonproject Initiative (NPI) the following objectives were identified. These objectives are consistent with both the intent of the State Environmental Policy Act and the State’s existing implementing rules. They are:

  1. Ensure that environmental values are considered and incorporated into proposals for nonproject actions.
  2. Provide decision-makers with an understanding of the environmental consequences of decisions on nonproject actions.
  3. Improve public involvement and input opportunities.
  4. Reduce costs and time by avoiding duplication and achieving early integration of SEPA and the development of a proposal.
  5. Implement an environmental review process to help formulate objectives and alternatives.
  6. Provide appropriate environmental analysis of actions that direct, encourage, or enable future "on the ground" activities (project actions).

Click to view/print the full pilot report (PDF)